Trusts can claim ER if the beneficiary of the IIP works in the qualifying company and the trusts hold the requisite amount of shares. What happens if the trust has more than one beneficiary - is the ER relief pro rated or can it be claimed in full (assuming not all beneficiaries work in the company).
As an example, Mr A transfers 20 shares (company has 100 shares in total) into trust for himself and his 2 children. Mr A continues to work in the company. The trust sells the shares at a gain. Is the whole gain subject to ER.
are there any links to the relevant HMRC manuals?
Thanks in advance
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